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WINE INSTITUTE PRIVACY POLICY

Last modified: October 5, 2021

Our Commitment to Your Privacy

This Privacy Policy applies to this website located at www.capstonecalifornia.com (the “Site”), which provides access to an online education course and certification program on California wines along with related study materials, content, resources and services as well as all other online and offline interactions with Wine Institute, including electronic communications between you and Wine Institute (collectively, the “Services”). This Site is owned and operated by the Wine Institute, a trade association located at 425 Market Street, Suite 1000, San Francisco, CA 94105 (“Wine Institute”, “we”, “our”, or “us”), in conjunction with and assistance by our third-party suppliers and vendors, including without limitation Thinkific Labs, Inc (“Thinkific”). Thinkific is a publicly listed company located at 369 Terminal Avenue, Suite 400, Vancouver, BC V6A 4C4 Canada. Thinkific provides Wine Institute with the underlying software platform we use to build and deliver our online educational courses. Students register with the online educational courses with an email address to access online study materials, do assignments, and take tests. Thinkific’s software platform enables Wine Institute to track student progress through the course(s)—including the percent completed and test scores—and collect the students’ names, emails, company names (optional), trade affiliation (optional). This Privacy Policy describes how we may collect, use, and share your Personal Information (as defined below) through your online and offline interactions with us in connection with the Services.

We understand you value your privacy. We protect Personal Information in accordance with applicable data protection laws. When referred to in this Privacy Policy, the term “Personal Information” includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, including any information that is subject to applicable data protection laws. This Privacy Policy applies only to Personal Information collected on this Site or otherwise in connection with the Services.

Please review this Privacy Policy in conjunction with our Terms of Service. By using the Services, you acknowledge that you have read this Privacy Policy. It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing your Personal Information.

Personal Information We Collect and Process

We collect and process certain information from you directly, such as information you enter yourself and data about your participation in courses.

Contact Information	When using our Services, you may provide contact information, such as your name, address, telephone number, email address, and date of birth.
Account Data	In order to use certain features of the Site (e.g., enrolling in a course), you need to create a user account (“Account”). When you create or update your Account, we collect and store the data you provide, such as your email address, password, date of birth, and account settings and assign you a unique identifying number (“Account Data”).
Profile Data	You can also choose to provide profile information such as a photo, biography, language, country, or other data (“Profile Data”). Your Profile Data will be publicly viewable by others.
Shared Content	Parts of the Services let you interact with other users or share content publicly, including by posting reviews on a course page, or submitting comments, questions, or feedback on the Site or otherwise in connection with the Services. Such shared content may be publicly viewable by others depending on where it is posted on the Site.
Course Activity Data	When you enroll in and take courses, we collect certain data including which courses you have started and completed; course purchases; course certificates; your exchanges with instructors and/or other users of the courses; and materials submitted to satisfy course requirements.
Payment Data	If you make purchases, we collect certain data about your purchase (such as your name and zip code/address) as necessary to process your order. All payment and billing data, including your name, credit card information, billing address, and zip code, is provided directly to our payment processing partners. For security purposes, we do not collect or store such payment processing data.
Surveys and Offers	We may invite you to complete a survey or participate in a promotional offer either through the Services or a third-party platform. If you participate, we will collect and store the data you provide as part of participating, such as your name, email address, postal address, date of birth, or phone number. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the offer or in another privacy policy.
Communications and Support	If you contact us for support or to report a problem or concern (regardless of whether you have created an Account), we collect and store your contact information, messages, and other data in connection with such communication.

We also collect certain information by automatic means, such as data about your device and browser characteristics.

System Data	Technical data about your computer or device, such as your IP address, device type, unique device identifiers, browser, domain and other systems data, and platform types (“System Data”).
Usage Data	Usage data about your interactions with the Site, including courses accessed, time spent on the Site, pages visited, features used, your search queries, click data, date and time, and other data regarding your use of the Site and Services (“Usage Data”).
Location Data	Approximate geolocation data (such as country) based on your IP address.

How We Collect the Personal Information

We may obtain Personal Information:

When you provide it directly to us through both online and offline interactions, such as via Site submissions or when you email us;
Automatically when you visit this Site or use the Services (such as from cookies, as further described below);
From our affiliates and partners including Thinkific, which provides Wine Institute with the underlying software platform we use to build and deliver our online educational courses, and Brillium Inc., which provides testing software integrated with Thinkific’s platform.

If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so.

Cookies and other similar technologies

This Site may use cookies, tracking pixels and other technologies (collectively, “Cookies”) to provide users an efficient experience in using the Site. We may also use these Cookies to better understand, customize and improve the user experience of our Site and Services. A cookie is a small data file that is placed on your computer or mobile device by your web browser, which stores information about website visits, recognizes you and your preferences each time you visit our Site, and ensures website functionality and enables us to provide the service which our customer’s request.

We use the following specific Cookies on our Site:

· Google Analytics

· MyFonts

· Login-Cookies

· Screen options cookies

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Website and use its functionalities.

Functionality Cookies

These cookies remember choices you make such as the country you visit our Site from, language and search parameters. This data can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized or pseudonymized and they cannot track your browsing activity on other sites.

Performance Cookies

These cookies collect anonymous or pseudonymous information on how people use our Site.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. Please note that if your browser is set to reject cookies, the Site may not recognize you when you return to the Site and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies and your choices with respect to collection and use of such data, you may visit www.allaboutcookies.org, or the Digital Advertising Alliance’s (DAA) opt-out page at http://www.aboutads.info/choices, or the National Advertising Initiative’s (NAI) opt-out page at http://www.networkadvertising.org/choices/.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they do not track the user. At this time, the Wine Institute does not track your or any other users’ Personal Information over time and across third party websites. We therefore do not respond to browser DNT signals, but this does not affect your privacy choices. For information about DNT, visit www.allaboutdnt.org.

How We Use the Personal Information and the Legal Grounds for Such Use

We may process the Personal Information that we collect in furtherance of our legitimate interests in providing you with the Services, to fulfill the terms of a contract you have with us (such as providing you with access to a course you are taking), with your consent, or in order to comply with our legal obligations. In some cases, failure to provide such Personal Information will mean that we cannot provide you with the Services.

Specifically, we process the Personal Information we collect for one or more of the following business and legal purposes:

operate our business (including to provide, personalize, and improve or otherwise develop this Site and our products and services);
provide and administer the Services, including to facilitate course enrolment, participation and certificates;
process your requests and orders for courses, products, specific services, information, or features;
respond to an inquiry and any related activity that may result from your inquiry;
market and administer surveys, promotional offers, and programs administered or sponsored by the Wine Institute or our partners;
ensure the security and integrity of this Site and its content;
manage our vendor and partner relationships;
enforce our Terms of Service and other legal terms and policies;
protect our and others’ interests, rights, and property (such as to protect our copyrighted materials); and
ensure compliance with local legal and regulatory requirements.

How We Share the Personal Information

We may share your Personal Information as described in this Privacy Policy or when you otherwise consent (to the extent required by law).

We share Personal Information with third parties in the following ways:

With instructors and other users of the Site, in connection with and as necessary for the facilitation of courses and other Services provided to you.
To authorized third-party service providers or others who may perform services on our behalf, such as payment processing, data analysis, marketing and advertising services, and customer service and support. These service providers may access and use your Personal Information to provide our requested service(s). In addition, we have entered into data processing agreements with these service providers, if required by applicable law.
If we believe disclosure is appropriate to prevent physical, financial, or other harm, injury, or loss.
To legal, governmental, or judicial authorities, if we believe it is appropriate, as instructed or required by those authorities or applicable laws, or in relation to a legal activity, such as in response to a subpoena or investigating suspected illicit activity.
As necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law or in accordance with the rules of the promotion or survey.
To the extent we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users (such data will not include information identifying you, without your consent).
We may disclose or use anonymized, aggregated or otherwise de-identified data for any purpose.
With your consent, or when we have a legitimate business or legal need to share your information, we may share data to third parties outside the scope of this Privacy Policy.
As necessary to pursue a legitimate business or legal need to share your information, such as meeting our contractual obligations or as part of our business relationship (and in accordance with applicable law).

A list of the service providers with whom we share your Personal Information is set forth below. This list may be updated at any time. Please check this Privacy Policy for the most current information.

We use the following service providers:

· Thinkific – Thinkific is a publicly listed company located at 369 Terminal Avenue, Suite 400, Vancouver, BC V6A 4C4 Canada. Thinkific provides Wine Institute with the underlying software platform we use to build and deliver our online educational courses.

· Mailchimp – Mailchimp is a marketing platform created by The Rocket Science Group, LLC which is located at 675 Ponce de Leon Avenue NE, Suite 500, Atlanta, GA 30308 that we use for email marketing.

· Mapbox, Inc. – Mapbox, Inc. is located at 740 15th Street NW, Suite 500, Washington DC 20005 and provides custom online maps we use for maps of various wine regions.

· Vimeo, Inc. – Vimeo, Inc. is located at 555 West 18^th Street, New York, NY 10011 and provides a video platform we use for educational videos.

· YouTube, Inc. – YouTube, Inc. is located at 901 Cherry Avenue, San Bruno, CA 94066 and provides a video platform we use for educational videos.

· Google Analytics – Google is located at 1600 Amphitheater Parkway, Mountain View, CA 94043 and provides a web analytics service we use to study user experience in aggregate to help us better understand how to improve navigation and usability.

Links To Third-Party Websites

The Site may contain links to other web sites. We have no control over and are not responsible for the privacy policies or practices of such sites. Whenever you link to another website, you may be asked to provide registration or other information. Please note that any information (including Personal Information) that you provide is going to a third party, and therefore you should familiarize yourself with that party’s privacy policy.

Information Security

We seek to use reasonable and appropriate physical, technical and administrative measures to protect the Personal Information that we collect and store. Unfortunately, no data transmission or storage system can be guaranteed 100% secure; therefore, we do not guarantee that your Personal Information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such Personal Information. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.

The safety and security of your information also depends on you. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or Account has been compromised, you should change it immediately.

Retention

Except to the extent prohibited by law, and subject to this Privacy Policy, we will retain and use your Personal Information for as long as it is needed to provide you with any Services, communications, or access to this Site, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Your Rights

Depending on your jurisdiction, you may have certain rights regarding our collection, use, and sharing of your Personal Information. If you have any questions regarding these rights, please contact us at: legal@wineinstitute.org. Please note that we may request additional information to respond to or fulfill any requests regarding your rights under applicable laws or regulations.

You can always opt out of any subscription for emails, involving any updates, information, postings, and/or news, by clicking “Unsubscribe” at the bottom of the email. We might still send you certain important emails, like responding to you by email if you send us a request or comment.

If you are a resident of Nevada, California, the European Union, Switzerland, or United Kingdom, you have additional rights. See the applicable “Your Rights” sections below.

Children’s Privacy

The Site is not intended for children, and our Service is only intended for adults. No one under the age of 18 may provide any Personal Information to the Site and we do not intend to collect Personal Information from children. Parents or adults can use various readily available software programs or other methods to prevent children or minors from accessing the Site. If you believe we might have any information from or about an individual who is under the age limit or for an unintended applicant on our Site, such as a child, please contact us.

Data Transfers

The Wine Institute is headquartered in the United States, and by engaging with us you consent that we can host your Personal Information in the United States. We have operations, entities, and service providers in the United States and throughout the world. We and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide levels of data protection equivalent to your home jurisdiction. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it. If you are located in the European Economic Area, United Kingdom, or Switzerland, we ensure an adequate level of protection is afforded where we transfer your Personal Information out of the EU/EEA by ensuring, where required by law, at least one of the following safeguards is implemented:

Transferring Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the EU Commission, or
Using specific contracts approved by the EU Commission which give Personal Information the same protection it has in Europe.

You may be entitled, in accordance with applicable law, to request a copy of the specific safeguard by contacting us as described below.

Data Subjects In The European Union (EU), the European Economic Area (EEA) and the United Kingdom (UK) – Legal Ground and Your Rights –

If you are located in the EU, EEA or the UK, the following applies additionally:

Legal Grounds for Processing

The processing of the above listed Personal Information is based on the following legal grounds:

· Contact Information / Account Data / Payment Data / Communication and Support / Shared Content / Course Activity Data: We process such personal data in order to comply with our contractual obligations with you, as follows:

Provide and administer our Services;
process your requests and orders for courses, products, specific services, information or features;
respond to an inquiry and any related activity that may result from your inquiry; and
post your reviews, comments, feedback and/ or questions on the Site.

· System Data / Usage Data: We process such personal data in order to protect the following legitimate interests:

· Surveys / Offers: We process such personal data in order to further our legitimate interests, as follows:

improving our Site and products; and
promoting our Services.

· Profile Data / Location Data: We will only process such personal data with your consent.

The sharing of Personal Information is based on the following legal grounds:

· With instructors / other user of the Site: in order to comply with our contractual obligations with you.

· As necessary to administer, market, or sponsor promotions and surveys: in order to comply with our contractual obligations with you.

· With legal, governmental, or judicial authorities: in order to comply with our legal obligations.

· As necessary to pursue a legitimate business or legal need / to prevent physical, financial, or other harm, injury or loss: in order to further our legitimate interests. Our interest is to provide our Services and prevent damages.

· With third party advertisers and networks / with third parties outside this Privacy Policy / aggregated or de-identified data: where we have your consent.

Data Subject Rights

Pursuant to the EU General Data Protection Regulation 2016/679 (GDPR) and where allowed by law, such as in the European Economic Area (EEA), United Kingdom, and Switzerland, and provided that the legal preconditions are fulfilled, if you are a resident of the EU, United Kingdom, or Switzerland, you have the right to:

access your Personal Information;
ask us to correct your Personal Information;
ask us to delete your Personal Information;
ask us to restrict processing of your Personal Information;
obtain your Personal Information in a structured, machine readable format for data portability purposes;
withdraw your consent at any time by emailing us at Legal@wineinstitute.org.

In addition, you can object to the processing of your Personal Information in some circumstances (including where we are using the data for direct marketing).

You further have the right to lodge a complaint with a data protection supervisory authority if you believe that our processing of your Personal Information does not comply with GDPR.

These foregoing data subject rights may be limited, for example, if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to keep or have overriding legitimate interests in keeping. You can find more information here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en

If you wish to contact us in relation to the exercise of any of your rights, please email us at: Legal@wineinstitute.org.

Your Rights – California Residents

Access to Specific Information and Personal Information Portability Rights

If you are a California resident, you have the right, subject to certain exceptions defined in the California Consumer Privacy Act (CCPA) and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past twelve (12) months. Please also note that we are not required to respond to your requests for access or disclosure of Personal Information more than twice in a twelve (12) month period.

This right of access includes information about:

· The categories of Personal Information we collected about you

· The categories of sources for the Personal Information we collected about you

· Our business or commercial purpose for collecting that Personal Information

· The categories of third parties with whom we share that Personal Information

· The categories of Personal Information that each recipient received

· The specific pieces of Personal Information we collected about you

Deletion Rights

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your Personal Information that it has collected from you and retained.

Non-Discrimination

California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed herein.

Request and Verification Process

When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.

You will be required to submit your first and last name and email address and may be asked to provide your telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.

Sale or Sharing of Personal Information

You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies stop selling your personal information and refrain from doing so in the future. We are not currently selling your Personal Information.

California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain Personal Information for direct marketing purposes. We do not share Personal Information with other people or non-affiliated businesses for their direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send a letter to the Wine Institute, 425 Market Street, Suite 1000, San Francisco, CA 94105. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.

Your Rights – Nevada Residents

Although the Wine Institute does not sell Personal Information, Nevada residents have the right to submit a verified request directing us not to sell their Personal Information. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods noted below at “Exercising Your Rights.”

Exercising Your Rights

To exercise your rights described above, please submit a request to us by either:

· Emailing us at Legal@wineinstitute.org ; or

By mail at: 425 Market Street, Suite 1000, San Francisco, CA 94105.

How to Contact Us

If you would like to contact us for any reason concerning our privacy practices, or if you would like to request that we update or correct any information that you have provided to us through your use of the Site or Services, or if you have suggestions for improving this Privacy Policy, please email us at info@wineinstitute.org.

Updates to this Privacy Policy

We may change or update portions of this Privacy Policy at any time at our sole discretion. The revision date appearing on the first page of this Privacy Policy underneath the title will identify the date of the last update or revision. Please check back from time to time so you are aware of any changes or updates to the Privacy Policy.